Skip to main content
Skip to content
Case File
efta-efta00032783DOJ Data Set 8Correspondence

EFTA00032783

Date
Unknown
Source
DOJ Data Set 8
Reference
efta-efta00032783
Pages
0
Persons
0
Integrity
Loading PDF viewer...

Summary

Ask AI About This Document

0Share
PostReddit

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: ' To: '1 (USANYS (USANYS)" Cc: =Mir Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Date: Thu, 22 Apr 2021 20:09:31 +0000 Attachments: 2021-04-22 Gov't letter re GM request_for_adjoumment v4.docx: 2021-04- 22=Ilietter re -_request_to_file_un—der_seal.docx Thanks very much, Attached please find a revised draft incorporating your edits. I've also attached a draft sealed letter informing AJN of From: (USANYS) Sent: Thursday, April 22, 2021 3:06 PM To: ) (USANYS) Cc: (USANYS) Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Thanks this is well done, and my edits are attached. As you'll see, I suggested >; Happy to look at another version before filing, thanks very much. From: Sent: Thursday, April 22, 2021 1:32 PM To: (USANYS) Cc: (USANYS) Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Draft response attached. From: Sent: Thursday, April 22, 2021 12:14 PM To: (USANYS) (USANYS) Cc: Subject: FW: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] (USANYS) cc > (USANYS) FYI. Our response is due at 5 today. From: Laura Menninger Sent: Thursday, April 22, 2021 11:22 AM To: Cc: 14t ); (USANYS) >; < >; Jeff Pagliuca ca; 'Bobbi Sternheim EFTA00032783 Y >; Nicole Simmons Subject: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Judge Nathan - Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an Adjournment of the trial. Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule 1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex reL Okla. Bar Ass'n v. McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the representation, whatever its source"). Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket. Best regards, Laura Menninger Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. EFTA00032784

Related Documents (6)

DOJ Data Set 8CorrespondenceUnknown

EFTA00014699

0p
DOJ Data Set 8CorrespondenceUnknown

EFTA00014710

0p
DOJ Data Set 8CorrespondenceUnknown

EFTA00027167

0p
DOJ Data Set 9OtherUnknown

From: '

From: ' y. „cl [Contractor]" (USANYSCo ntractor " (USANYS) [Contractor To: ' Cc: ' (USANYS ) [Contractorr <W " ) (USANYS)" Subject: RE: Discovery Issues Date: Wed, 12 May 2021 13:54:21 +0000 Great, thanks very much. Let's say 11am? From: (USANYS) [Contractor] < Sent: Wednesday, May 12, 2021 9:43 AM To: (USANYS) [Contractor] Cc: Subject: Re: Discovery Issues As am I. On May 12, 2021, at 9:36 AM, From: Sent: Tuesday, May 11, 2021 10:41 PM To: (USANYS) [Contractor] < (USANYS) [Contractor] (USANYS) [Contractor] < M> Cc: (USANYS)<a Subject: FW: Discovery Issues and I are both available anytime today. (USANYS) [Contractor) (USANYS) (USANYS) [Contractor] < wrote: Hi team, Maxwell's attorneys have asked for the below-listed information from the SUPP production that went out on November 9, 2021. Is there a time tomorrow when we can have a call to discuss, please? Thanks, From: Laura Menninger Sent: Friday, May 7, 20214:53 PM To: >; Christian Everdell

7p
DOJ Data Set 9OtherUnknown

To: Laura Mennin er tennin e

From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca ipagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM' <bcstemheim@mac.com> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 27 Mar 2021 22:38:06 +0000 Inline-Images: image001.jpg Counsel, Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12rh. Physical Evidence • It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can revi

10p
DOJ Data Set 9OtherUnknown

To: Laura Mennin. er •

From: To: Laura Mennin. er • Jeff Pagliuca Cc: '1 >, aff,IJSANrai > ) 4° Subject: RE: [EXTERNAL] Proposed Jury Questionnaires Date: Wed, 13 Oct 2021 01:35:59 +0000 Attachments: 2021.10.12 Joint_proposed_Maxwell_Trial_Length_Letters _v3.pdf Thanks, Laura. This works for us — we've just added a couple sentences noting our production yesterday to our section. I'll plan to file this at 10. Shanks From: Laura Menninger Sent: Tuesday, October 12, 2021 7:58 PM To: Pagliuca ‹ > Cc: ) (USANYS) Subject: RE: [EXTERNAL] Proposed Jury Questionnaires < >.H > ; Jeff Thanks. Here is our position for the joint letter. I'll leave to your discretion whether you want to keep the final paragraph of your position given it is redundant of the joint position. Also, I'm not clear why our report to you would be spelled out in your position rather than ours, so I moved it. Thanks — Laura From: Sent: Tuesday, October 12, 2021 5:46 PM To: Laura Menninger Cc: (USANYS) •t > Subject

8p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.

Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.